Melbourne's angriest carriage driver appears to have again been caught on camera venting his spleen, this time hurling racial abuse and violent threats during an animal rights protest on Valentine's Day.

Footage of the incident, posted on Facebook by Animal Liberation Victoria, shows the coachman in a heated argument with protesters taking part in a rally against the controversial carriages.

The driver returns to his carriage before calling the man a "black bit of s--t".

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Sunday's rally was held by a group called Melbourne Against Horse-Drawn Carriages, which says the carriages are cruel to the animals and should be banned.

The coachman in the video appears to be the same man who in December 2014 was filmed swerving his carriage towards a cyclists outside Flinders Street Station after the cyclists ask him to "stay out of the bike lane please".

A City of Melbourne spokesman said the driver involved in Sunday's incident did not hold a council permit, meaning he could only take passengers around the city on pre-arranged bookings.

The spokesman said the council could not stop unregistered carriages from entering the city, because they are legal vehicles, and encouraged people to ensure carriages had a permit before hiring them.

He said stopping unregistered operators was difficult because the council had to prove they collected a customer off the street without a booking.

"We have to follow the customer and interview them when they get out, and ask them if that person approached them or offered them a ride," he said.

The matter then has to go to court and the customer - who are often interstate or overseas tourists - need to appear as a witness.

"So it's not just like giving out a parking fine," the spokesman said.

A VicRoads spokeswoman said horse-drawn carriages did not need to be registered and drivers did not need a licence to travel on public roads because the vehicles are not motorised.

"Like a cyclist however, they are expected to obey the road rules," the spokeswoman said.